Can We Trust AI? 

We see the use of Artificial Intelligence or AI all around us in uses that may be visible to us as also in uses not directly visible to us. It is here to stay and as we learn to live with it, however, there remains a concern about whether we can totally trust AI. Hollywood may have painted a picture of the rise of machines that may instill fear in some of us. Fear of AI taking over jobs, of AI reducing intelligent human beings, and of AI being used for illegal purposes. In this article we discuss what actions can be taken by organizations to build trust in AI, so it becomes an effective asset. The idea is as old as 1909, EM Foster’s “The Machine Stops”. 

What does it mean to trust an AI system? 

For people to begin to trust AI there must be sufficient transparency of what information AI has access to, what is the capability of the AI and what is the programming that the AI is basing its outputs on. While I may not be the guru in AI systems, I have been following its development over the last seven to eight years delving into several types of AI. IBM has an article that outlines the several types of AI that may be helpful. I recently tried to use ChatGPT to provide me with information and realized the information was outdated by at least a year. To better understand how we can trust AI, let us look at the factors that contribute to AI trust issues.  

Factors Contributing to AI Trust Issues 

A key trust issue arises in the algorithm used within the neural network that is delivering the outputs. Another key factor is the data itself that the outputs are based upon. Knowing the data that the AI is using is important in being able to trust the output. It is also important to know how well the algorithm was tested and validated prior release. AI systems are run through a test data set to determine if the neural network will produce the desired results. The system is then tested on real world data and refined. AI systems may also have biases based on the programming and data set. Companies face security and data privacy challenges too when using AI applications. Additionally, as stated earlier there remains the issue of misuse of AI just as cryptocurrency was in its initial phases.  

What can companies do to improve trust in AI? 

While there is much to be done by organizations to address the issues listed above and it may take a few years to improve public trust in AI, companies developing and using AI systems can use a system-based approach to implementing these systems. The International Organization for Standardization (ISO) recently published ISO/IEC 42001 – Management System Requirements for Information Technology AI systems. The standard provides a process-based framework to identify and address AI risks effectively with the commitment of personnel at all levels of the organization.  

The standard follows the harmonized structure of other ISO management system requirement standards such as ISO 9001 and ISO 14001. It also outlines 10 control objectives and 38 controls. The controls based on industry best practices asks the organization to consider a lifecycle approach to developing and implementing AI systems including conducting an impact assessment, systems design (to include verification and validation), control of quality of data used and processes for responsible use of AI to name a few. Perhaps one of the first requirements that organizations can do to protect themselves is to consider developing an AI policy that outlines how AI is used within the ecosystem of their business operations.  

Using a globally accepted standard can deliver confidence to customers (and address trust issues) that the organization is using a process-based approach to responsibly perform their role with respect to AI systems. 

To learn more about how QMII can support your journey should you decide to use ISO/IEC 42001, or to learn about our training options, contact our solutions team at 888-357-9001 or email us at info@qmii.com.  

-by Julius DeSilva, Senior Vice-President

Are Medical Audits Improving Systems Or Only Driving Fixes? 

Is there a potential downside to medical audits wherein the audits are focused on finding and fixing problems? A recent discussion with a medical professional piqued my interest in the value of Medical Audits given that QMII, a subject matter expert in auditing, has ventured into the medical auditing field. This led to a conversation with a few additional healthcare professionals to understand a little more about medical audits, their findings and how organizations address them. My additional reading outlined a lack of effective systemic corrective action. In this article, I discuss some aspects of the medical audit process and what organizations can do to improve the process of audits and of implement corrective action.  

There are various types of medical audits including clinical audits, billing/coding audits, financial audits, operational audits and compliance audits. While there are regulations, protocols and standards against which these audits are conducted, in many cases, industry-best practices are also used as audit criteria. This brings subjectivity into the audit as ‘best practices’ knowledge may vary from auditor to auditor based on their experience. Auditing to an auditor’s experience has a major drawback not just in the medical industry but in all industries. It takes the auditors away from requirements which then results in biased inputs to the leadership that may be inaccurate.  This also leaves the auditee (the organization being audited) on the receiving end of findings for which there are no certain requirements. That is, they may make changes to their system based on the finding of one auditor only to find that another auditor objects to the very actions they implemented based on the previous auditor. 

Medical Audits and Recommendations 

In medical audits, it is common practice for auditors to provide recommendations to address findings. These recommendations are based on experience and industry-best practices. In ISO audits this is not allowed. In most industries, including the healthcare industry, there is no obligation to act upon any of the recommendations of an auditor. However, if auditors are perceived to be in a position of authority, then there is an underlying implication that the audit recommendation must be implemented. This is for fear of the nonconformity occurring again only for someone to say, “the auditor told you what to do and no action was taken”. This then also implies, audits do not delve deeply enough to identify systemic weaknesses within the processes or the workflow. 

In speaking with the medical professionals within my professional circle of friends, it was surprising to hear that in many cases the personnel being asked to address the audit findings are unaware of any root cause analysis methodologies nor have they been given any formal training in the subject. Further, they are not clear about what a CAPA is but do know that they need to provide some action to close out the finding. In such cases, is it then fair to expect effective corrective action? Perhaps, the lack of effective corrective actions perpetuated the need for auditor recommendations! 

Without proper training, it is but natural for personnel responding to audit findings to default to the recommendations of the auditor and implement those actions prescribed by the auditor as the corrective action in and of itself. Sadly, in such cases the root cause of the issue goes unaddressed. Sometimes such cases may lie in inadequate resources, technology or even lack of guidance/policy from leaders. While the aim of the audits is to identify where the process may require additional controls, all for providing better healthcare for the patient, the outcome may only be a band-aid. 

What can be done to change this? 

While change may not come overnight, there are a few key steps that can be taken to improve the audit process overall right up until corrective action and meet the end goal of providing better healthcare.  

Auditor training – Auditors must be trained to remain objective through the audit process, to focus on the requirements (criteria) of their audit, to focus on factual evidence and objectively assess it (yes, no experience!). Further they must understand the implications of providing recommendations and thus not provide any recommendations. The auditors are but to focus on assessing the effectiveness of the corrective action plan submitted and verifying the effectiveness of actions taken.  

Root Cause Analysis Training – Healthcare organizations must invest in providing their personnel with training in the different root cause analysis methodologies and how to apply it to identify the root cause(s) of a problem.  

Reinforcing that Recommendations need not be accepted/addressed – Organizations must be professional to build the courage to stand up to auditors and not accept recommendations. Auditors do not know all facets of the process from the short sample of the organization they witness. If their “advice” in the recommendations is wrong/ineffective, who then pays the price? 

Auditor Selection – ISO 19011 provides guidance on the behaviors and skills that an auditor should exhibit, and these are applicable to an auditor selected to conduct any type of audit. Auditors must be evaluated periodically to ensure they are remaining objective through an audit and working to identify the effectiveness of controls and adequacy of resources in assessing if the overall objectives have been met. To learn more about how QMII can support your organization’s audit process, click here. 

–Julius DeSilva, Senior Vice-President

Responsibly Implementing Artificial Intelligence

Artificial Intelligence (AI) entered our lives stealthily and not before long has become an integral part of all we do. From choosing a playlist, to self-driving cars, to providing service desk support to name a few. Some people have openly embraced AI while others approach it more cautiously afraid of the domination and ‘rise of the machines. Along with the opportunities that AI presents, also come risks and therefore responsibility. ISO in December of 2023 published a management system standard, ISO/IEC 42001, that provides a framework for organizations looking to use a process-based approach to managing risks and opportunities associated with use of Artificial Intelligence.

What is AI system?

As defined by ISO/IEC 22989 and artificial intelligence system is and engineered system that generates outputs such as content, forecasts, recommendations, or decisions for a given set of human-defined objectives. Artificial intelligence can then further be broken down into various subcategories from weak AI to strong AI. There are also various associated terms that are used within the industry that wall within the realm of Artificial Intelligence systems. These include Autonomous AI system, Machine Learning, and Cognitive Computing to name a few.

An integrated standard approach

In structuring the standard ISO/IEC follows the harmonized 10 clause structure that is applicable to standards such as ISO 9001 and ISO 45001. This will make it easy for organizations seeking to integrate the requirements into their existing management system. Like other ISO management system standards, ISO/IEC 42001 is not prescriptive within the standard clauses. It does however, similar to ISO/IEC 27001 include an Annex of controls that must be considered and that must be justified when not applicable. Annex A has a total of 38 controls that are split among the 10 control objectives. As a risk-based standard it requires organizations to conduct an impact analysis, conduct a risk assessment and then implement controls to treat the risk to an acceptable level.

ISO/IEC 42001 control areas

The 10 control areas of Annex A intend to:

  • Provide management commitment and direction
  • Establish organizational accountability
  • Determine and provide resources
  • Assess the AI system impacts
  • Provide a framework for managing the AI system life cycle
  • Control data used within AI systems
  • Provide a framework for communication with interested parties
  • Ensure responsible use of AI systems
  • Mange relationships

ISO/IEC 42001 also makes reference to the NIST Risk Management Framework, developed to better manage risks to individuals, organizations, and society associated with artificial intelligence (AI).

Next Steps for Companies seeking to align to ISO/IEC 42001

If your organization is seeking to demonstrate a responsible use of AI systems and choosing to align with the ISO /IEC 42001 framework, the next steps would be to:

  1. Conduct as “As-Is” assessment – Identify what controls and resources are already in place within the existing management system.
  2. Conduct an Impact Assessment – Annex A controls provide a structure of how to achieve this and Annex B provides further guidance. This requirement supports the requirements of the EU AI Act. Inputs to the assessment will come from an understanding of the organizational context and the needs of the interested parties.
  3. Conduct a Risk Assessment – to identify potential risks and opportunities for users and society. The assessment should include the implication for deploying AI systems.
  4. Develop Risk Treatment Controls – Identify measures that the organization will implement to mitigate the risks to an acceptable level and then a plan to ensure the effectiveness of controls implemented.
  5. Implement and monitor the controls and system, with an aim to driving continual improvement and ensuring the responsible use of AI.

To learn more about how QMII can support your implementation of ISO/IEC 42001 reach out to QMII solutions team at info@qmii.com or call us at +1 (888) 357-9001.

-By Julius DeSilva, Senior Vice-President

10 Steps to Safeguard Maritime Property from Cybersecurity Threats

IJ Arora, Ph.D

Cybersecurity threats have become a pressing concern in the modern era due to our lives becoming increasingly dependent on computerization. However, with the convenience of technology comes vulnerability to malicious attacks. The maritime industry, with a growing reliance on technology, faces significant cybersecurity threats. Dr. Jekyll and Mr. Hyde (i.e., good and bad) exist and have always existed. Protecting against cyberattacks is crucial to ensuring the industry’s stability and security.

Understanding cybersecurity in the maritime industry

Cybersecurity in the maritime sector involves safeguarding systems, information, and assets from unauthorized access, disruptions, or manipulations. The industry’s growing reliance on technology, including networks controlling essential functions like navigation and communication, makes it an attractive target for cybercriminals. To maintain business continuity, it is crucial that companies assess their current cybersecurity posture and act to proactively improve it. The maritime industry supports trade and the economy at large, so a cyberattack can have broader consequences beyond just affecting a single vessel or company. For this reason, the intent of the attackers might be broader than simply affecting a specific entity for ransom.

Current challenges in maritime cybersecurity

Before delving into the 10 essential steps to fortify against cyberthreats, it’s crucial to acknowledge the prevalent challenges faced by the maritime industry, which include:

  • Business continuity disruption due to breaches
  • Lack of comprehensive response plans
  • Growing reliance on automation
  • Insufficient awareness
  • Vulnerabilities in cloud computing
  • Rise in phishing and social engineering attacks
  • Internal threats and attacks

Controlling both information technology and operational technology systems is critical to fortifying cybersecurity. Various systems within the small passenger-vessel sector are susceptible to cyberthreats, including bridge systems, access control systems, passenger servicing and management systems, and communication systems.

The 10 steps

When addressing cybersecurity, organizations must consider protecting information itself as well as the asset on which that information is stored. Control of both information technology (IT) and operational technology (OT) systems is critical to fortifying cybersecurity. Additionally, management must consider the confidentiality, integrity, and availability of information and how these three aspects may potentially be compromised.

Step 1: Leadership commitment

Leaders must drive the need for cybersecurity and ensure that it is baked in (not buttoned on) to processes. They need to engage the workforce to contribute to the system. To do this, they can:

  • Appoint a cybersecurity manager to ensure accountability and garner buy-in.
  • Make cybersecurity integral to business processes and consider risks vs. rewards.

Step 2: Use a system framework

Employ the plan, do, check, act (PDCA) cycle as the foundation for a robust cybersecurity approach. This is also the approach prescribed by the Passenger Vessel Association (PVA) safety management system (SMS) framework.

  • Develop and regularly update cybersecurity policies aligning with organizational needs and threat landscape changes.
  • Identify clear roles and responsibilities for all concerned with cybersecurity aspects of the SMS.

Step 3: Contextualize risk

  • Consider the broader context of operations, trade patterns, technology, and legislative factors.
  • Identify stakeholders, online networks, assets, critical components, and business-sensitive information.

Step 4: Risk assessment (3D framework)

Leaving hazards in uncertain states is a drawback for proper risk assessment. It is the responsibility of leadership to convert uncertainty into clearly defined risks within the context of the organization and then prioritize those risks.

  • Organizations must assess hazards in terms of probability, severity, and the likelihood of detection.
  • Risks should be prioritized with consideration given toward confidentiality, integrity, and the availability of information.

Step 5: Build controls into processes

Controls can be split into various categories, including administrative, physical, human, and technological. In some cases one control may suffice, but for the most part a combination of controls must be applied. Identified controls should be implemented based on the feasibility rule, meaning that although they may look good in a vacuum, ease of implementation must be considered. Information security should be a part of everything the organization does—not an add-on. This includes:

  • Implementing technical security controls like firewalls and intrusion-detection systems.
  • Adopting a layered security approach (i.e., “defense in depth”) to effectively mitigate against various threats. This entails creating multiple barriers to prevent access to information—physical, passwords, firewalls, VPNs etc.

Step 6: Maintain basic measures

Basic safety measures are easy to implement and, for the most part, they are cost-effective. This can include cybersecurity awareness training for personnel, physical security, and password security. Below are a few more, although this is not an exhaustive list:

  • Keep hardware and software updated.
  • Enable automated antivirus and anti-malware updates.
  • Limit administrator privileges and control removable media.
  • Avoid public network connections without a VPN.
  • Regularly backup and test information-restoration capabilities.

Step 7: Employee awareness

It is important to make employees aware of the need for good cybersecurity protocols. Employees are often the weakest link in the security chain. Statistics show that almost 36 percent of data breaches are caused by employee negligence. Immediate actions organization can take include:

  • Educate employees on cybersecurity best practices to minimize human error.
  • Train personnel to identify phishing attacks and report incidents promptly.

Step 8: Emergency preparedness

No organization is immune to cyberattacks. It is important to have a plan in place for responding to attacks quickly and effectively. The plan should include steps for mitigating the damage, containing the attack, and investigating the incident. You can use ISO 22301: 2019, “Business continuity,” to develop this plan.

  • Your plan should include comprehensive processes for responding to cyberattacks swiftly and efficiently, including reporting mechanisms.
  • Test and improve your business continuity plan regularly.

Step 9: Assess effectiveness

The check stage of the PDCA cycle is vital to instill confidence in the effectiveness of the organization’s cybersecurity measures.

  • Conduct regular cybersecurity assessments, including third-party evaluations for objectivity.
  • Evaluate assets, vulnerabilities, IT/OT risks, physical access, and breach potentials.

Step 10: Continual improvement

  • Embrace continual improvement through the PDCA cycle to maintain vigilance.
  • Invest in training personnel on cybersecurity standards like ISO 27001.

Conclusion

Taking cybersecurity seriously and implementing these 10 steps can significantly mitigate the risk of cyberattacks. Begin the process by conducting a gap assessment using a qualified person to assess where your system currently stands and what actions need to be taken.

Your action plan should identify risks, gaps, and the controls needed. These controls can easily be integrated into the existing safety management system. Investing in cybersecurity today will better prepare your organization to manage future risks. Leadership involvement is crucial, and these steps serve as a solid foundation to effectively fortify cybersecurity measures.

About the author

Inderjit (IJ) Arora, Ph.D., is the President and CEO of QMII. He serves as a team leader for consulting, advising, auditing, and training regarding management systems. He has conducted many courses for the United States Coast Guard and is a popular speaker at several universities and forums on management systems. Arora is a Master Mariner who holds a Ph.D., a master’s degree, an MBA, and has a 33-year record of achievement in the military, mercantile marine, and civilian industry.

Above article is featured in the following:-

Foghorn Magazine

Exemplar Global Publication “The Auditor”

P-D-C-A with a Christmas Tree


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As a QMII employee, I can sit and observe classes whenever I want, more so since they are virtual instructor led these days. It allows me to get a refresher on the clauses, even though it is so hard to get them. It gets me every time. When the time comes to interview auditees, I smile like a Cheshire cat; not a confident grin but one that hopefully does not betray my nervousness.  Often, I am nervous as a long-tailed cat in a room full of rocking chairs. However, my QMII ISO lead auditor training has prepared me well. I am nervous as the auditee too, even though I know audits are not about pass or fail.  While I call myself a writer and researcher my greatest struggle perhaps lies with Audit Report writing. Oh, man! QMII lead auditor training, however, well prepared me to gather all notes during an audit to present a valuable report to the auditee. Smile.

The aspect of Lead Auditor training I like is the P-D-C-A cycle because I can use that analogy anywhere in my life. I have the responsibility of putting up the tree, however, currently, my application of the P-D-C-A is not going so well. Perhaps a re-plan is needed?

So from the Lead Auditor classes that I have attended, P-D-C-A stands for the following and the task next to it is what I have to do:-

P – Planning: We have to put the tree. Also, the objective of my mission. Considerations include where are the decorations kept, do we have enough, do we need a ladder, what should be the first step, then the next (like testing the lights before we put them on the tree), and more. Most important plan the time to do it in my busy schedule!

D – Do: Now to put my plan into action! Locate the boxes, get them out, unpack, and, get my team to help me even if they don’t want to (just to cheer me on perhaps). Yay! Thanks guys, for your help! Thumbs up for that. Basically, everything else that needs to be completed before the tree is finally up and lit up and everyone is happy. The DO stage can be extremely exhausting. How about that drink to cool me down?

Note – From my Lead Auditor training and also when I am auditing my clients, I know that the ‘DO’ section of the process is where a lot of the “action” happens. Just because “you gotta do it, man, get on with it!” I feel the pain of the “Do’s” as it is easy sometimes to plan but more taxing to put the plan into action. Now getting back to my tree.

C – Check: Once the tree is up and you think the job is over, it is not. You have to wait for the others to “check” the tree out and give their opinions. Pass comments, critique your effort while you are bickering away that they didn’t do anything, but they get to analyze it. What was that? Oh yes, I agree it is just an opportunity for improvement and we love our non-conformities.

A – Act: The verdict is out. The tree looks great. Beautiful decorations. However, the lights seem to flicker at some places, we need better lights for next time. Get more decorations. Good job!

VERDICT

Plan it better next time. Stop bickering when you are doing the job. Be patient and stop being

grumpy when they are “checking” and analyzing your work. Continually Improve this process till you get your Act together – words of a wise Yoda who is enjoying the view of the Christmas tree and listening to the Christmas songs.

Can I get that drink now? Long Island, please. Merry Christmas!

Is your organization ready for MDSAP?

Quality is important in all industries but perhaps more so in the medical industry and for those organizations producing medical devices. Apart from ISO 13485 that defines the requirement for medical device quality management systems, medical device manufacturers have to also comply with the regulations of the country their devices are going to be used within. In an effort to streamline the program for manufacturers the Medical Device Single Audit Program (MDSAP) was devised. The MDSAP program is an audit done of the company to the regulations of five participating countries. It is thus much longer than a regular ISO audit as it has to assess the system against multiple regulatory requirements.  

As your company prepares for this new audit scheme perhaps the easiest thing to do is a self-assessment. Use the MDSAP audit model guide to assess whether the company processes meet all the requirements. Conduct a gap assessment and then work to fill in the gaps including keeping records as needed by MDSAP. Just because an organization undergoes MDSAP does not mean that it will not have an ISO 13485 audit as these are two separate schemes. In the conduct of the assessment ensure that the person conducting it is competent to do so. This will avoid any last-minute surprises. Make note that the MDSAP model grades non-conformities differently and so use the same scoring scheme to know what are the priorities that need to be addressed immediately.  

Is the leadership prepared? Often in preparing an organization focuses on the lower echelons as also on the processes involved in the design and manufacturing processes. Ensure the leadership is briefed on the model guide and understands the expectations from them. As a part of each audit, the AO focuses on the management and assesses their commitment to the system. The leadership once committed will drive the rest of the organization to follow suit. This will make it easier for those implementing the system and assessing it internally.  

Make sure personnel are trained and understand well the expectations. QMII offers a variety of MDSAP offerings that are tailored to meet the requirements of the organization with training for each level of the organization. In addition, QMII also offers ISO 13485 lead auditor training. Organizations must recognize that participating in MDSAP will not exclude them from regulatory audits from other organizations. While the audit program may seem cumbersome at first there are benefits from participating in it that include reduced costs and a streamlined audit process.  

How will ISO 22301 Benefit you?


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What is ISO 22301?

ISO 22301 is an international standard for Business Continuity Management Systems. This standard is designed to protect, prepare for, respond to, and recover from unexpected incidents when they arise. When your organization has a Business Continuity Management System, it is prepared to detect and prevent unforeseen threats.

ISO 22301 applies to all organizations no matter the size or industry. In 2012, when this standard was first developed, it was the world’s first international standard for implementing and maintaining effective business continuity plans, systems, and processes. It was revised in late 2019 to bring it up to date with current best practices and is based on the High-Level Structure (HLS).  Consequently, it aligns well with many other internationally recognized management system standards including ISO 9001 (quality management) and ISO 14001 (environmental management).

What are the benefits of being ISO 22301 certified?

There are many possible threats that organizations face including supply chain issues as we saw in the recent pandemic, or natural disasters such as earthquakes, floods, hurricanes, and tornadoes, and even cyber-attacks such as the recent news with the ransomware attacks on the oil and gas and food industries. These are major threats, but there are even other types of risks, such as the loss of skilled labor, power outages, and IT breakdowns that can cause disruption to a business.

How is a certification in ISO 22301 beneficial to an individual?

With a certificate in ISO 22301, you will be able to help your organization meet its business objectives and gain the necessary knowledge to manage a team in the implementation of this standard.

If your organization does not have a Business Continuity plan, then they may be at risk.  It is important to take these plans seriously or your business could suffer consequences. Some impacts of not having a plan include business failure, damaged reputation, loss of data and clients, and business interruption.

 What will students learn about ISO 22301 from QMII?

During ISO 22301 five-day training at QMII, students will understand how to respond effectively based on the procedures that apply before, during, and after an event. It is important for an organization to implement a Business Continuity plan because it shows that you are prepared for the unexpected. This assures that your business will continue to operate without any major impacts or losses. Our training enables you to develop the necessary expertise to perform a Business Continuity Management System (BCMS) audit by applying widely recognized audit principles, procedures, and techniques.

 

Implementing Safety Management Systems for Passenger Vessels

PV SMS White Paper – FinalExcerpt below is from White Paper by ‘Implementing Safety Management Systems for Passenger Vessels’ by Dr. Inderjit (IJ) Arora (QMII), Julius Desilva (QMII) and Captain Lee Boone (USCG, Retired). To continue reading the paper click on link in text.

INTRODUCTION

All too often, major accidents are the catalyst for change in the maritime industry. Evidence of this is seen in the development and implementation of maritime conventions and codes in existence today. The International Safety Management (ISM) Code, the result of such a catalyst, was meant to change this reactive nature. The ISM Code intended to promote a safety culture wherein risks are properly considered, work is effectively planned, personal accountability is enhanced, and operations are continually improved.

Unfortunately, this target was missed in many cases and a pervasive by-product called compliance culture set in, wherein the system achieves the minimum and only to satisfy regulators. The maritime industry and regulators learned much from this experience. We know now that if the true value of safety management systems (SMS) is not realized, further implementation efforts become self-defeating. This leads to even more than normal resistance from many who have seen colleagues, shipmates and competitors negatively impacted. A carefully planned implementation strategy expanding the use of safety management systems (SMS) to domestic passenger vessels should therefore be executed to avoid these pitfalls. As Safety Management Systems for domestic passenger vessels are intended in the same way as those for SOLAS1 vessels, we must apply lessons that have been learned from similar regulatory efforts.

In this paper, recommendations are made for implementing SMSs for domestic passenger vessels (PV) based on the concepts of incentives, scalability, and collective use of resources. When implemented in the right way and for the right reasons, the value that SMSs offer passenger vessel owner/operators is maximized, while the cost of implementation is minimized.

BACKGROUND – RESISTANCE TO CHANGE

Looking at the data from the 1980’s to date, one would expect to see a decline in marine casualties starting in 1998 when the ISM code’s first compliance deadline came into effect. Initially the data shows a downward trend for a few years and then a spike starting in 2001. Those resisting change brought about by the ISM code would argue that the code had not delivered any improvements. However, the upward trend peaked in 2008 and has since seen a decline.

When a new management system is put in place, irrespective of industry, the first sign of success albeit non-intuitive, is a spike in accidents, incidents and hazardous occurrences. This leading indicator should be accepted as a positive as it demonstrates that the personnel within the system have started reporting non-conformities that went unreported before. This reporting enables corrective action to be taken in a systematic manner to prevent a similar non-conformity from occurring again.

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